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We're adding an 'accept cookies' GDPR banner across the bottom of our site.

Should it be the first thing that gets focus when tabbing into the page?

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Yes it should be the first item that gains focus, even before 'skip links'. It is the only use case I can think of where 'logical tab order' does not apply.

To comply with GDPR you must alert users to the fact you use cookies BEFORE you add cookies to your site (except for functional cookies such as session cookies which you must inform about but can be implemented before confirming they are ok with this.) and get explicit consent that you can use cookies. (they must click accept cookies before they are activated and have an option to decline cookies and you not activate them)

Screen reader users therefore need to know that the page uses cookies before they interact with the page at all so that they can give consent otherwise you can't switch cookies on.

Also you must inform a user what cookies your page uses, including essential cookies. You must also let them edit their preferences and make sure you tell them where and how they can do this once the accept. This all has to be done when someone first lands on the site.

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